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TMI Blog2010 (7) TMI 151X X X X Extracts X X X X X X X X Extracts X X X X ..... pplication for condonation of delay of 100 days in refiling the appeal. For the reasons stated in the application, delay of 100 days in refiling the appeal is condoned. Accordingly, application stands disposed of. ITA 941/2010 1. The present appeal has been filed under Section 260A of Income Tax Act, 1961 (for brevity "Act, 1961") challenging the order dated 19th June, 2009 passed by the Incom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r Assessment Years there has been no disallowance on account of this imprest account of Shri V.K. Chabra. It is also noticed that the assessee company is having substantial share capital and reserves and surplus par in excess of the amount given by the assessee to Shri V. K. Chabra. It is also noticed that the amount given to Shri V.K. Chabra has not been claimed as expenditure either. It is also ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... igh Court in Commissioner of Income Tax Vs. Sridev Enterprises, (1991) 192 ITR 165 has held that a departure from a finding in respect of deductions permitted during the past years would result in a contradictory finding. 5. We are also of the view that it would not be equitable to permit the Revenue to take a different stand in respect of expenses which were the subject matter of previous years' ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r to Paris, London, Amsterdam and Hong Kong had apparently no connection with the business of the assessee. It is noticed that the assessee is in the business of textile and garment manufacturing. The disallowance has been made on presumption and the disallowance is an ad-hoc disallowance. The details of the expenditure have been found to have been produced before the Assessing Authority. Ld ..... X X X X Extracts X X X X X X X X Extracts X X X X
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